10 E. Memorial Road
Oklahoma City, OK 73114
RE: The tariff classification of electronic switches from China
Dear Ms. Chowning:
In your letter dated April 4, 2016 you requested a tariff classification ruling.
The items under consideration are referred to as the “Z-Wave In-Wall Occupancy/Vacancy Motion Sensing Switch” (Item #24770 and #26931) and Dimmer versions of the same switch type (Item #26933 and #26932). These wall mountable electrical switches are comprised of up and down manual pushbuttons, a passive infrared (PIR) motion sensor, a microprocessor, a relay, a power supply printed circuit board assembly (PCBA), a radio frequency (RF) PCBA, and metal contacts for the connected wires. The Dimmer version of this switch incorporates a TRIAC (TRIode for Alternating Current) which enables the device to dim connected lights. A sample was submitted with your ruling request and is being returned as requested.
The In-Wall Occupancy/Vacancy Motion Sensing Switch and Dimmer are designed to replace a standard wall switch. They may be controlled wirelessly through the RF PCBA by interfacing with a compatible Z-Wave device controller or the user can interact with the switches manually by depressing the front panel buttons. The PIR motion sensor resides on the front panel in between the two pushbuttons. You state that the purpose of the PIR motion sensor is to detect room occupancy and through programmable features, the user can set certain modes where the lights will turn off automatically when the room is vacant for a certain time or may turn on automatically when a person walks into the room.
However, whether wirelessly, manually, or automatically, it is the microprocessor that is directing the relay and/or TRIAC to open or close and thereby supplying power to the connected device. We would note that both switch types incorporate a single relay/TRIAC, which can connect only one electrical load to a power source. They are rated at 15A and are intended to be hardwired to the building’s electrical supply.
Based on the information provided, the applicable subheading for the Z-Wave In-Wall Occupancy/Vacancy Motion Sensing Switches and corresponding Dimmers will be 8536.50.7000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits… for a voltage not exceeding 1000 V: Other switches: Other: Electronic switches, including temperature protected switches consisting of a transistor and a logic chip (chip-on-chip technology)." The rate of duty will be Free.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Karl Moosbrugger at [email protected]
Deborah C. Marinucci
National Commodity Specialist Division